What the skilled artisan would "recognize" or have considered "obvious" is not necessarily determinative of "inheren[cy]." Schering Corp. v. Geneva Pharmaceuticals, 339 F. 3d 1373, 1377 (Fed. Cir. 2003). The Examiner appears to be conflating certain standards for demonstrating inherency with those for demonstrating obviousness. In relying upon the theory of inherency, the examiner must provide a basis in fact and/or technical reasoning to reasonably support the determination that the allegedly inherent characteristic necessarily flows from the teachings of the applied prior art. Ex parte Levy, 17 USPQ2d 1461, 1464 (BPAI 1990); MPEP § 2112.

"The purpose of the written description requirement is to prevent an applicant from later asserting that he invented that which he did not." Amgen Inc. v. Hoechst Marion Roussel, Inc., 314 F.3d 1313, 1330 (Fed. Cir. 2003).